GML Partners Privacy Policy

Last updated: 1 September 2025

This Privacy Policy describes how GML Partners Limited and its affiliates (“GML Partners”, “we”, “our”, “us”) collect, use, share, and protect personal data when you visit or use our website (https://www.gmlpartners.com), or otherwise interact with us (e.g. as a candidate, client, contact). It also describes your rights with respect to your personal data and how you can contact us.

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1. Definitions
• Personal Data (or “personal information”) — any information relating to an identified or identifiable natural person (e.g. name, email address, phone number).
• Processing — any operation performed on personal data (collection, storage, usage, disclosure, deletion, etc.).
• Controller — the entity that determines the purposes and means of processing personal data.
• Processor — a party that processes personal data on behalf of the controller.
• Data Subject — the individual whose personal data is processed (e.g. candidate, client, website visitor).

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2. Scope and Legal Basis

This Policy applies to all personal data processed by GML Partners in relation to:
• Use of our website(s)
• Engagement with candidates (recruitment, evaluation, placement)
• Client relationships (communications, contracting, service delivery)
• Business contacts and marketing
• Any other interactions (e.g. inquiry forms, events, etc.)

To the extent applicable, we process personal data based on one or more of the following legal bases:
• Your consent
• The performance of a contract (e.g. recruitment services)
• Compliance with a legal obligation
• Our legitimate interests (provided that your rights and freedoms are not overridden)

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3. What Data We Collect

We may collect and process the following categories of personal data:

Category Examples / Specifics
Identity / Contact Information Name, job title, employer, business address, email address, telephone number
Professional / Background Information Resume/CV, employment history, education, skills, certifications, references
Communications Data Emails, messages, call records, meeting notes
Usage Data / Technical Data IP address, browser type, device identifiers, cookies, operating system, pages visited, time spent
Special / Sensitive Data If voluntarily provided (e.g. disability status, health information, diversity data) — processed with extra protections as required
Other Data Any other information you provide to us (e.g. via forms, surveys, events)

We collect data from:
• You (candidates, clients, contacts)
• Our website (automated tools, cookies, analytics)
• Third parties (e.g. references, background check providers, public sources)
• Service providers (e.g. HR or recruitment platforms)

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4. How We Use Your Data & Purpose of Processing

We use personal data for the following purposes (and legal bases):

Purpose Data Used Legal Basis / Justification
To provide recruitment / search / matching services Identity, professional background, communications, references Performance of contract / your consent / legitimate interests
To evaluate and assess candidates Professional history, references, assessments Performance of contract / legitimate interest
To communicate with clients, candidates, contacts Contact data, communications data Performance of contract / legitimate interest
To send marketing / promotional communications Contact data, preferences Consent / legitimate interest (where allowed)
For analytics, website improvement, security Usage data, technical data Legitimate interest
To comply with legal and regulatory obligations As required by applicable law Legal obligation
To maintain records, audits, dispute resolution All relevant data Legitimate interests / legal obligations

We will not process your personal data for other purposes incompatible with those listed unless we notify you in advance.

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5. Cookies and Tracking Technologies

We (and third-party service providers) use cookies, web beacons, and similar tracking technologies on our website to:
• Distinguish you from other users
• Improve website functionality and performance
• Analyze trends and usage
• Enable certain features (e.g. “remember me”)
• Provide advertising or marketing insights

You can configure your browser settings to refuse cookies or alert you when cookies are being sent. However, doing so may affect the functionality of the site.

We may also use third-party analytics (e.g. Google Analytics), advertising networks, social media plugins, etc. (subject to applicable laws).

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6. Disclosure & Sharing of Personal Data

We may share your personal data with:
• Affiliates and subsidiaries
• Clients (especially when placing candidates)
• Service providers / subcontractors (e.g. IT providers, email, analytics, background check vendors)
• Professional advisors / auditors
• Regulators, courts, law enforcement as required by law
• Third parties in connection with business transactions (e.g. merger, sale)

Whenever we transfer data to third parties, we require them to protect your data in accordance with applicable law and only use it for permitted purposes.

If data is transferred outside your jurisdiction (e.g. outside the EEA for EU users), we will ensure adequate safeguards (e.g. standard contractual clauses, binding corporate rules, or other lawful basis) are in place.

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7. Data Retention

We retain personal data for as long as necessary for:
• The purposes for which it was collected
• Complying with legal, regulatory, tax, accounting, or reporting obligations
• Establishing, exercising, or defending legal claims

After the retention period, data will be securely deleted or anonymized.

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8. Security

We implement appropriate technical and organizational measures to protect personal data against unauthorized or unlawful processing, accidental loss, destruction or damage, including:
• Access controls, encryption, secure servers
• Regular security reviews and updates
• Employee training, confidentiality obligations
• Incident response plans

However, no security measure is perfect; in case of a breach, we will notify you and relevant authorities as required by law.

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9. Your Rights

Depending on your jurisdiction, you may have rights including:
• Right to access your data
• Right to rectify inaccurate or incomplete data
• Right to erase (“right to be forgotten”)
• Right to restrict or object to processing
• Right to data portability
• Right to withdraw consent at any time (for consent-based processing)
• Right to lodge a complaint with a supervisory authority

To exercise your rights or for any data privacy concerns, contact us (see Section 11 below).

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10. Children & Minors

Our services are generally directed to professionals, clients, and business users. We do not knowingly collect data from children.

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11. Contact Information

If you have questions, requests, or complaints regarding your personal data or this Privacy Policy, please contact:

GML Partners Limited
Archer House
Britland Estate, Northbourne Rd
Eastbourne, BN22 8PW
Email: privacy@gmlpartners.com

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12. Changes to This Privacy Policy

We may update this Policy from time to time. Changes will be posted on our website with a revised “Last updated” date. Where required by law, we may notify you (e.g. via email) of material changes.

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13. Jurisdiction & Governing Law

This Policy is governed by the laws of [the jurisdiction where GML Partners is incorporated / where you operate]. Disputes arising under or in relation to this Policy or personal data processing will be subject to the competent courts of that jurisdiction or as otherwise required by law.